International cooperation between governments on fiscal affairs and administrative transparency has a key role in counteracting the phenomena of tax evasion and tax avoidance.
It is common for multinational enterprises around the world to finance their associated subsidiaries in high-level tax jurisdictions through issuing debts rather than equities.
In Part I, Gabriel Magalhães Borges Prata examined Brazil’s thin capitalisation regime. He concludes this discussion here.
The ever growing number of transactions involving MNEs over the past decade has resulted in transfer pricing becoming increasingly important.
The Russian government has joined the ranks of a great number of other jurisdictions which are seeking to introduce mandatory reporting requirements on the unreported capital of its citizens, placed, until now, in offshore locations.
In Part I, Okan Netek introduced the Turkish corporate tax system related to international taxation. This discussion continues here in Part II.
The term cloud is used by the information and communication technologies (ICT) industry to indicate, primarily, virtual platforms or infrastructures that allow the execution of codes (services, applications, among others) in various forms across multiple resources, with relevant data.
In this final part, Peter Wilson concludes his discussion of Article 12. Parts 1-3 appeared in the previous three issues of ITR.
As a newly industrialised country Turkey is among those developing countries closest to the league of developed nations.
The concept of beneficial ownership in the OECD model tax convention 2014: A critical analysis – Part II
In Part I of his article on beneficial ownership, Dr Maxim Kotlyarov discussed the economic and social objectives of double taxation treaties, which are intended to contribute to wealth creation and social stability, focusing on the beneficial ownership concept in the context of the OECD Model.
The concept of beneficial ownership in the OECD model tax convention 2014: A critical analysis – Part I
Tax avoidance and tax evasion schemes undermine the foundations of wealth of developed and developing countries.
The Organisation for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project has been creating considerable debate and discussion in the international tax community.
Investment and Indirect Taxes
In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.
In Parts 1 and 2, which appeared in the March and April issues, Maria Cecilia Rossi discussed Cloud Computing and its interaction with the concept of permanent establishment. Here, in Part 3, she concludes her discussion.